UC Migration and the 12 month disregard for capital

I have a fairly complex query I hope someone could provide assistance with:

Client was on tax credits, told to move to UC. Had UC stopped because her capital limit was over £16,000. This was due to partly owning a home. However upon doing an MR the decision was overturned as they did not apply the 12 month disregard as should normally be applied for migrated claimants to UC.

all good so far - I am in the process of establishing when the 12 month disregard will end.
Client is currently in the process of getting her name taken off the house. She is currently going through a divorce and just wants to give the house to her ex. She states that this is because she can’t live in it as her son is disabled and it is unsuitable for adaptation and that her ex cannot afford to buy her out so she just wants her name taken off it and receive nothing. She will hear in July from her solicitors if she is able to do this. Her question is; once the 12 month disregard is up can the DWP then state that she has deprived herself of capital? I imagine they may/can and her reasons may be good enough?

I think the answer could be…. maybe… and we’d just have to wait and see what a decision maker states?
Though if her name is taken off the house well before the disregard ends , will they even realise the situation in order to make a deprivation of capital decision? 

Thank you for any advice/help in advance

Have the DWP / HMRC valued the house?

I believe they have yes.

The ADM seems to draw the DM’s attention to the fact that there’s nothing to stop intentional deprivation being considered:
https://assets.publishing.service.gov.uk/media/656083bf3d7741000d420157/admm7.pdf

M7353 After the end of the 12 assessment periods, the normal capital rules apply, so that if capital continues to exceed £16,000, UC entitlement ends.
Note: See Chapter H1 (Capital) for detailed guidance on the calculation of capital including notional capital.

Lovely thank you for your reply.